Hamdard Health Alliance

2025-004: Health Centers Cluster - ALN# 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), ALN# 93.527 Grants for New and Expanded Services under the Health Center Program, June 30, 2025 - Eligibility Criteria: Under the terms and conditions of the Health Center Program award, the Organization is required to determine participant eligibility for sliding fee scale discounts based on reported household income and family size, and to apply the required discount percentage in accordance with the approved sliding fee scale schedule. Condition: For a sample of client accounts tested, the Organization did not consistently apply sliding fee scale discounts in accordance with the approved schedule. In 11 of 40 client files tested, the discount percentage applied did not agree with the discount level supported by the participant’s documented income and family size, or the file lacked sufficient documentation to support the income level used. As a result, participants were charged amounts that were not consistent with program requirements. Effect: Failure to correctly determine and document income-based discount levels increases the risk that participants are overcharged or undercharged relative to program requirements and that amounts billed to or reported under the program are not accurate. This may result in improper payments, questioned costs, or the need for refunds or adjustments to amounts charged to participants or reported to the grantor. Questioned Costs: $36,465 (based on the projected difference between amounts that should have been charged under the approved sliding fee schedule and amounts actually charged for the instances identified). Cause: The Organization’s controls over documenting income determinations and applying the approved sliding fee scale were not operating effectively. Staff responsible for determining and entering discount levels did not consistently follow documented procedures, and there was no documented supervisory review to verify that discounts were calculated and recorded in accordance with the approved schedule. Recommendation: Management should strengthen controls over the sliding fee scale process by: (1) ensuring staff obtain and retain appropriate documentation of household income and family size in the participant file; (2) implementing a standardized worksheet or system control to calculate the required discount percentage based on the approved sliding fee schedule; and (3) implementing a documented supervisory review to verify that the discount level recorded in the billing system agrees to the approved sliding fee scale and supporting documentation prior to billing. Views of Responsible Officials: Management agrees with the finding and a response is included in the Corrective Action Plan.

2025-004: Health Centers Cluster - ALN# 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), ALN# 93.527 Grants for New and Expanded Services under the Health Center Program, June 30, 2025 - Eligibility Condition: For a sample of client accounts tested, the Organization did not consistently apply sliding fee scale discounts in accordance with the approved schedule. In 11 of 40 client files tested, the discount percentage applied did not agree with the discount level supported by the participant’s documented income and family size, or the file lacked sufficient documentation to support the income level used. As a result, participants were charged amounts that were not consistent with program requirements. Corrective Action Plan • Enhancing documentation requirements to support fee determinations in client records • Providing training to all relevant staff on sliding fee scale policies and compliance expectations. CFO will prepare a lunch and learn to demonstrate the calculations and answer questions. • Establishing supervisory review procedures to ensure proper application and documentation. CFO and revenue cycle staff will sample a number of encounters each month to ensure accuracy and will retrain staff that continue to miss the mark. Responsible Person for Corrective Action Plan CFO Implementation Date of Corrective Action Plan 6/30/2026

2024-002

2024-002: Health Centers Cluster – ALN# 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), ALN# 93.527 Grants for New and Expanded Services under the Health Center Program, June 30, 2024 - Special Tests and Provisions Criteria: The Organization must prepare and apply a sliding fee discount schedule (SFDS) so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. Condition: The Organization did not retain documentation or other evidence that patients were eligible for adjustment (discount) that was received. We consider this finding to be instances of noncompliance with regard to the Special Tests and Provisions compliance requirement. Effect: By not retaining the proper documentation it would possible for patients to receive services they were not eligible for. Questioned Costs: $0 Cause: Control procedures did not function as designed as applications were not completed by patients, leading to the finding with special tests and provisions. Recommendation: Management should review the control procedures in place related to sliding fee procedures and ensure proper documentation is collected for each patient to determine proper sliding fee eligibility. Views of Responsible Officials: Management agrees with the finding and a response is included in the Corrective Action Plan.

2024-002: Health Centers Cluster – ALN# 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), ALN# 93.527 Grants for New and Expanded Services under the Health Center Program, June 30, 2024 - Special Tests and Provisions Condition: The Organization did not retain documentation or other evidence that patients were eligible for adjustment (discount) that was received. Corrective Action Plan: Patient Service Representatives are responsible for ensuring sliding fee schedule docuemtns are current. We have implemented another layer of oversight to ensure moving forward, we will be able to identify any patients with expired documentation for the sliding fee scale application. The PSR Lead will run a monthly report in the EMR to capture any information that may have been inadvertently missed and will help us ensure updates are completed accurately and in a timely manner. A report was run initially for the current fiscal year and will be run monthly going forward to identify expired applications so we can update accordingly. Responsible Person for Corrective Action Plan: Director of Operations and PSR Leads Implmentation Date of Corrective Action Plan: April 16, 2025

GSA_MIGRATION

GSA_MIGRATION